giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
RESPONSE TO MOTION TO COMPEL ATTORNEY-CLIENT COMMUNICATIONS
AND ATTORNEY WORK PRODUCT MATERIALS
BOIES, SCHILLE…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.14_2
40 pg
…Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
RESPONSE TO MOTION TO COMPEL ATTORNEY-CLIENT COMMUNICATIONS
AND ATTORNEY WORK PRODUCT MATERIALS
BOIES, SCHILLE…
giuffre-maxwell
1320-18
40 pg
…Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
RESPONSE TO MOTION TO COMPEL ATTORNEY-CLIENT COMMUNICATIONS
AND ATTORNEY WORK PRODUCT MATERIALS
BOIES, SCHILLE…
giuffre-maxwell
gov.uscourts.nysd.447706.839.0
3 pg
…Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
____________________________/
DECLARATION OF MEREDITH SCHULTZ IN SUPPORT OF
PLAINTIFF’S BRIEFING REGARDING DEFENANT’S FAILURE TO COMPLY WITH
THIS COURT’S ORDER TO PRODUCE HER ELECTRONIC DOCUMENTS AND
…
giuffre-maxwell
gov.uscourts.nysd.447706.970.0
2 pg
…the conference. We
had not received any communication from counsel for intervenor Cernovich as
of the time we said we would need to submit this letter to the Court.
Very truly yours,
Ty Gee
C: Counsel of Record (via ECF);…
giuffre-maxwell
gov.uscourts.nysd.447706.139.0
7 pg
…Accordingly, communications by law
enforcement to Ms. Giuffre are privileged under the law enforcement privilege.
1
Case 1:15-cv-07433-LAP Document 139 Filed 05/04/16 Page 2 of 7
The law puts a very high burden…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.1
7 pg
…s Unseal in full (no applicable Brown minimal redactions or yet-
Motion to Compel all to-be-noticed Non-Party names)
Attorney-Client
Communications and
Work Product Put At
Issue by Plaintiff and
Her Attorneys
Unseal in full…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…During that call, Epstein himself got on the
phone (a means of interstate communication) with Jane Doe #4, asking her personally to come to
his mansion in Palm Beach.
Jane Doe #4 then went to Epstein’s mansion and was…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.6
10 pg
…During that call, Epstein himself got on the
phone (a means of interstate communication) with Jane Doe #4, asking her personally to come to
his mansion in Palm Beach.
Jane Doe #4 then went to Epstein’s mansion and was…
giuffre-maxwell
1320-9
10 pg
…During that call, Epstein himself got on the
phone (a means of interstate communication) with Jane Doe #4, asking her personally to come to
his mansion in Palm Beach.
Jane Doe #4 then went to Epstein’s mansion and was…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.3
10 pg
…During that call, Epstein himself got on the
phone (a means of interstate communication) with Jane Doe #4, asking her personally to come to
his mansion in Palm Beach.
Jane Doe #4 then went to Epstein’s mansion and was…
giuffre-maxwell
gov.uscourts.nysd.447706.1050.0
12 pg
…frankly, not every
22 recipient of these notices is the kind of person that has a
23 lawyer on speed dial.
24 We also think that it can be hard to -- communications
25 are more difficult now. So we certainly…
giuffre-maxwell
gov.uscourts.nysd.447706.1353.0
6 pg
…subject to certain enumerated exceptions, the Act re-
quires the Attorney General to “make publicly available … all unclassified records, documents,
communications, and investigative materials in the possession of the Department of Justice, in-
cluding the Federal Bureau of Investigation…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…of
Torts § 587 (1977) (“A party to a private litigation or a private prosecutor or
defendant in a criminal prosecution is absolutely privileged to publish defamatory
matter concerning another in communications preliminary to a proposed judicial
proceeding, or in the…
giuffre-maxwell
gov.uscourts.nysd.447706.968.0_1
26 pg
…of
Torts § 587 (1977) (“A party to a private litigation or a private prosecutor or
defendant in a criminal prosecution is absolutely privileged to publish defamatory
matter concerning another in communications preliminary to a proposed judicial
proceeding, or in the…
giuffre-maxwell
gov.uscourts.nysd.447706.978.0
27 pg
…of
Torts § 587 (1977) (“A party to a private litigation or a private prosecutor or
defendant in a criminal prosecution is absolutely privileged to publish defamatory
matter concerning another in communications preliminary to a proposed judicial
proceeding, or in the…
giuffre-maxwell
gov.uscourts.nysd.447706.977.0
27 pg
…of
Torts § 587 (1977) (“A party to a private litigation or a private prosecutor or
defendant in a criminal prosecution is absolutely privileged to publish defamatory
matter concerning another in communications preliminary to a proposed judicial
proceeding, or in the…
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